City of Lake Charles - McNeese Water Plant - Executive Summary

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    Mcneese Water Plant 
    LDEQ Facility  ID Number - 25182 
    a)  Accidental Release Prevention and Emergency Response Policies 
    The City of Lake Charles Water Division is strongly committed  to employee, public, and    environmental safety.  We are aware that the use of some of our treatment chemicals could      pose a risk to the public under certain circumstance s.  We therefore are committed to development of a comprehensive risk management program for the Mcneese plant.  The program will address areas such as design, installation, operating procedures, maintenance, 
     and employee training  associated with the chlorine processes at our facilities.  S afety depends    upon the manner in which we handle and operate the regulated process.  The use of chlorine     has been standard in the water treatment industry for many years and the safety of its use has improved greatly throughout that time.  The inherent safety of the vacuu 
m operated chlorination system combined with safe handling procedures make the use of chlorine a reliable 
    process.  Indepth and ongoing training programs for our personnel will make the use of    chlorine even safer for our employees and the members of the surrounding community.   It  is our policy to implement appropriate controls to prevent p ossible releases of any regulated substance.   
    Unforeseeably, if such a release does occur, we have met with and coordinated our  release      planning with the City of Lake Charles Fire Department which provides hi ghly trained      emergency response personnel to control and mitigate the effe cts of a release.  The procedures developed under this plan have also been included in the local community response plan as required under the rule.  Plant personnel have been trained on how and when to notify emergency responders if the need arises. 
    b)  The Stationary Source and the Regulated Substance Handled 
    The Mcneese water pl a 
nt is a municipal water treatment facility.  Our facility's primary   purpose is the tr eatment and disinfection of potable water for drinking and other uses.  We     have on e regulated substance at the facility.  Chlorine gas is  used in the treatment process as an oxidizer of dissolved iron in the water and as the primary disinfectant to inhibit microbial growth.  Chlorine ton containers are delivered to the facility on regular basis and off loaded and stored for use.  There are normally two ton containers stored for use at this site. The maximum amount of chlorine stored at this plant is 4,000 pounds or two ton containers.  Only authorized and trained personnel perform maintenance on or operate the regulated process. 
    c) The Worst-Case Release Scenario and the Alternative Release Scenario, including   administrative controls and mitigation measures to limit the distances for each reported  scenario 
    To perform the required offsite consequence analysis for the Mcneese plan 
t we used the    modeling plan furnished by the EPA, RMP Comp. Vers. 1.06.  The following paragraphs  provide details of the chosen scenarios. 
    The worst case scenario involves a catastrophic release of chlorine gas from the Mc neese  facility.  The entire contents of a ton container (2000 pounds) is released in gaseous form over    a period of 10 minutes.  This scenario assumes an atmosphe ric stability Class F, and a wind speed of 1.5 meters/second (3.4 miles/hour). A maximum distance with a 1.3 mile radius is obtained, corresponding to a toxic endpoint of .0087 mg/L. 
    An alternativ e release scenario was developed using the same model as above.  The alterna tive  release scenario was based on a release which occurs from the failure of the 5/16 inc h valve   opening located at the top of the ton container.  400 pounds  of gaseous chlorine escapes over a period of forty minutes.  The alternative release scenario assumes an atmospheric Stability Class D, wind speed of 3.0 met 
ers/second (6.7 miles/hour), relative humidity of 50%, and a temperature of 77 degrees F.  Under these conditions a maximum distance with a 0.1 mile radius is obtained , corresponding to a toxic endpoint of .0087 mg/L chlorine. 
    d) The General Accidental Release Prevention Program and the Chemical Specific  Prevention Steps 
     Our facility has taken all the necessary steps to comply with the accidental releas e prevention     requirements set out under 40 CFR part 68 of the EPA.  The facility was des igned and built     in 1958 in accordance with all applicable standards in place at that time.  The facility is regulated under the Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA) section 103(a).  The facility is also subject to the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA)  Section 302. We file Tier 
    Two forms for chlorine as well as other treatment chemicals.  The following sections briefly   describe  
the elements of the release prevention program that is in place at the stationary source. 
    Process Safety Information - The City of Lake Charles Water Division maintains a detailed      record of safety information that describes the chemical and physical hazards of chlorine.  We      also compiled and developed operating parameters  and equipment design information associated with all aspects of the process.   
    Process Hazard Review - Our facility conducts studies to ensure that the hazards  associated    with our chlorine process are identified and any deficiencies corrected.  We  use a checklist   developed for our chlorine system designed to be site  specific.  The hazard reviews are performed by qualified personnel knowledgeable in design and safety practices.  The review of hazards are designed to be updated every five years or upon changes to the process.  Any deficiencies in the initial hazard determination are expected to be addressed in a timely manner.  
ting Procedures - For the purpose of safely conducting activiti es within our covered      processes, The City of Lake Charles Water Division develop s and maintains operating  procedures.  These procedures address various modes of o peratio n such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown.  We plan to have procedures for the above developed and implemented within the next year or sooner. Complete  training will be given to all personnel on these procedures.  The procedures will be reviewed and updated on an ongoing basis. 
    Training - The City of Lake Charles Water Division plans to implement a comprehensive     training program for our employees to ensure that those persons who are operating the chlorine 
    process are competent .  We have developed training information that cover items such as  unloading of ton containers, storage of ton containers, installing the chlorinators on a container, 
general parts used in the chlorination system, general operation of the chlorination system,   troubleshooting of chlorine feed problems, maintenance of chlorine system,  hazards associated 
     with the chlorine process, and reporting requirements in case of a release.  Although we have  certified that our personnel are competent to operate the chlorine process we have decided to  implement the full range of training as if all were new employees.  We expect to have all initial training completed by January 1, 2000.  Refresher training will be given at a minimum of every 
    three years but more realistically much sooner. 
    Mechanical Integrity (maintenance) - The City of Lake Charles Water Division has developed  
    equipment and process lists to document and give suggested repair and replacement    information on its' chlorination equipment.  These steps are taken to improve process reliability 
    and safety.  Inspections of the chlorine feed systems will be performed on a 
yearly basis to   determine if any changes need to be made to our maintenance procedures and information.  
    Maintenance operations are carried out by qualified personnel with previous training in   maintenance practices.  These personnel are offered specialized training as needed.  Any  equipment deficiencies identified by the maintenance checks a re corrected in a safe and timely manner.  Manufacturers' manuals on all equipment is kept on file for review as needed. 
    Compliance Audits - The City of Lake Charles Water Division has initiated a compliance audit  
    during the initial phase of the RMP program.  The initial audit determined deficiencies we have 
    in the program and sets out time frames for completion of deficient items.  These will be      addressed in a timely manner.  Future audits will be performed at a minimum of every three     years to document and confirm whether the provisions set  out under the RMP rule are being implemented on a continuing basis. 
   Incident Investigations - The City of Lake Charles Water Division will promptly investigate any 
    kno wn incident that has resulted in, or could reasonably result in a release of a regulated    substance.  These investigations will be undertaken to determine the situation that led to the      incident, as well as any corrective actions to prevent the release from reoccurring.  All reports will be retained for a minimum of five years. 
    Employee  Participation - The City of Lake Charles strongly believes th at process safety and    accident prevention is a team effort.  Company employees are encouraged to express their  views concerning accident prevention issues and to recommend improvements.  Our employees have access to all information created as part of this facility's  implementation of the RMP rule. 
    Contractors - Contractors on occasion perform specialized maintenance or construction on  regulated processes and/or equipment.  We ensure that they will follow all p 
rocedures     regarding repairs to the process equipment.  All contractors  are given information pertaining to the known hazards of chlorine and how to recognize our labeling and information systems. 
    e) The Five Year Accident History 
    The Mcneese water plant has had an excellent record of preventing accidental releases of  chlorine over the last five years.  Due to safety and release prevention policies, there has been   no accidental release during this period. 
    f) Emergency Response Program 
    Since The City of Lake Charles Fire Department will be the first responders to any regulated   release of chlorine we have coordinated our emergency response program through their office.  
    We have met with officials from the Fire Department to provide complete information  on    locations and inventories of chlorine at the Mcneese water plant. Their personnel are hig hly   trained in emergency response and mitigating the effec ts of a release.  We have planned training  
for their personnel at our facilities to give them hands on training in the use of the ton container repair kits.   We will determine appropriate procedures for notification of affected areas in case of a release as well as proper notification of state and local agencies as required.  
    The stationary source will be included in the community emergency response plan as required.  
    We will provide all information developed for emergency response to the Calcasieu Parish  Emergency Planning Committee.  Our personnel will be trained to assist the Fire Department     personnel as needed and requested. 
    g) Planned Changes to Improve Safety 
    While preparing our plan it is apparent that we need to develop a much more extensive     training program for our operators and maintenance personnel on the risks, hazards, and use    of the chlorine process at our water treatment plants.  We plan  to provide indepth training that covers these areas.  After training,  some form of compete 
ncy testing or interviews will be used 
    to document and confirm that they have gained sufficient knowledge t o operate the process      in a safe and efficient manner.   We plan to improve the safety of th e chlorine sites by  providing additional chlorine leak detection systems tie d into our SCADA system at the GH West water plant which is manned continuously.  Additional operational procedures concerning the use of chlorine at the remote plants will be initiated in the future.  These and other changes should improve the reliability and safety of the chlorine systems.
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